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Correspondence

HOGAN & HARTSON LLP

875 Third Avenue

New York, NY 10022

July 16, 2009

Correspondence Filing Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 4561

450 Fifth Street, NW

Washington, D.C. 20549

    Attn:

    Cicely LaMothe

Wilson K. Lee

    Re:

    Apartment Investment and Management Company

File No. 001-13232

Form 10-K for the year ended December 31, 2008

Ladies & Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange Commission
(the “Staff”) addressed to David Robertson and Paul Beldin on behalf of Apartment Investment and
Management Company (the “Company”), in a letter dated July 1, 2009. The Company’s response to the
Staff’s comment is set forth below and is numbered to correspond to the numbering of the Staff’s
comment in the Staff’s letter.

* * * * *

Financial Statements and Notes

Consolidated Statements of Income, page F-4

    1.

    Comment: We have considered your response to comment one. We continue to believe the
presentation of the impairment losses as part of operating income is appropriate. Given the
large amounts of your impairment losses, we are unable to agree with your materiality
analysis. Please revise your filing accordingly to reclass the provision for impairment
losses for operating real estate and real estate development assets within operating income
and tell us your consideration regarding any requirements to file an Item 4.02 8-K.

Response: The Company and its independent registered public accounting firm continue to believe
the classification of impairment losses for operating real estate and real estate development
assets are not material to an investor based on the quantitative and qualitative

United States Securities and Exchange Commission

July 16, 2009

Page 2 of 3

factors outlined in Staff Accounting Bulletin No. 99 (“SAB 99”). However, the Company notes that
the Staff believes that the presentation of impairment losses within operating income is
appropriate. Therefore, as confirmed in its prior correspondence with the Staff, the Company
intends to classify impairment losses for operating real estate and
real estate development assets as part
of operating income in future filings. The Company respectfully submits that for the reasons set
forth in its prior letters, and as further explained below, revising the Form 10-K for the year
ended December 31, 2008, should not be required and any reclassification of these amounts should be
limited to future filings.

I respectfully refer the Staff to a comment letter received by FelCor Lodging Trust Incorporated
(“FelCor”) on June 19, 2006 regarding FelCor’s Annual Report on Form 10-K for the year ended
December 31, 2005 (the “FelCor Letter”). In the FelCor Letter, the Staff stated: “We note you
classify impairment losses related to your hotel properties as a component of non-operating income
(loss) in your consolidated statements of operations. In future filings, please revise your
statement of operations to present impairment losses related to properties held for use as a
component of operating income (loss).” FelCor’s 2005 impairment loss was $263 million, or 224% of
operating income. Notwithstanding the obvious significance of the impairment loss to Felcor’s
operating income, the Staff did not request that Felcor’s historical results be restated.

In contrast to Felcor, the Company’s operating real estate impairment losses and impairment losses
on real estate development assets totaled approximately 56% of operating income. Consistent with
the approach taken with Felcor, the Company respectfully requests that the Company be permitted to
classify its impairment losses within operating income in future filings and not be required to
revise its Form 10-K for the year ended December 31, 2008. The Company does not believe the
judgment of a reasonable person relying on its financial statements would be changed or influenced
by the inclusion of the impairment losses in operating income versus non-operating income because
the impairment loss amounts can be determined from the face of the financial statements and
therefore, there is no concern that investors could be misled by the disclosure.

In addition, the Company examined Item 4.02(a) of Form 8-K in light of the anticipated
reclassification in future years and related circumstances. While the Company agrees to reclassify
the impairment losses within operating income in future filings, the Company has concluded that the
previously disclosed financial results could continue to be relied upon because the anticipated
reclassification does not affect its key performance indicators, in particular reported net income
and stockholder’s equity, for any previous years. The Company also consulted with its independent
auditors who informed the Company that they currently do not intend to deliver the notice contemplated by
Item 4.02(b) of Form 8-K. As a result, the Company concluded that no Form 8-K was required under
Item 4.02.

As noted above, the Company will present the impairment losses within operating income in the
future in accordance with the Staff’s request. However, the Company continues to believe that it
should not be required to restate prior year financial statements because (a) for the reasons
stated in the Company’s prior letters, the classification is not material, (b) the Company applied
the accounting principles in a manner that was intended to provide transparency to investors, (c)
the Company’s application of the accounting principles was
reviewed by its independent auditors and they did not object to the Company’s presentation of the

United States Securities and Exchange Commission

July 16, 2009

Page 3 of 3

impairment
losses and (d) restating prior results would be unduly disruptive in light of the
foregoing. Further, this approach is consistent with the Staff’s approach with regard to another
similarly situated registrant. If the Staff disagrees with this approach, I respectfully request
the opportunity to meet in person with representatives of the Company, its independent auditors and
with representatives from the Staff.

If you have further questions regarding the information provided, please contact me at (212)
918-8270 (phone) or (212) 918-3100 (facsimile).

    Sincerely,

    /s/ Amy Bowerman Freed

    Amy Bowerman Freed

    Hogan & Hartson LLP

    Cc:

    Lisa R. Cohn, Aimco

David Robertson, Aimco

Paul Beldin, Aimco

APARTMENT INVESTMENT AND MANAGEMENT COMPANY

4582 South Ulster Street Parkway, Suite 1100

Denver, Colorado 80237

July 16, 2009

Correspondence Filing Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 4561

450 Fifth Street, NW

Washington, D.C. 20549

    Attn:

    Cicely LaMothe

Wilson K. Lee

    Re:

    Apartment Investment and Management Company

File No. 001-13232

Form 10-K for the year ended December 31, 2008

Ladies and Gentlemen:

In connection with responding to comments raised by the Staff of the Securities and Exchange
Commission (the “Commission”) in a letter dated July 1, 2009, with respect to the above-referenced
Form 10-K for the year ended December 31, 2008, Apartment Investment and Management Company (the
“Company”) acknowledges that: (a) the Company is responsible for the adequacy and accuracy of the
disclosure in its filings; (b) Staff comments or changes to disclosure in response to Staff
comments do not foreclose the Commission from taking any action with respect to the filings; and
(c) the Company may not assert Staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

If you need additional information, please contact the undersigned at (303) 691-4554 or David
Robertson, President, Chief Investment Officer and Chief Financial Officer, at (303) 691-4311.

    Sincerely,

    /s/ Paul Beldin

    Paul Beldin

Chief Accounting Officer